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FBAR Guard

Do closed foreign bank accounts still count for an FBAR?

Updated

Short answer

If you must file for that year, yes. An otherwise reportable foreign account that was open at any time during the calendar year goes on that year's FBAR, even if you closed it before December 31. The report covers the whole year, not just the accounts open at year end.⁠Source 1⁠Source 2

Opening a foreign account doesn't by itself create a filing requirement. You must still meet the U.S.-person, foreign-account, financial-interest or authority, and combined $10,000 tests. Once you must file, a closed account belongs on the report even if its final balance was zero.⁠Source 1⁠Source 2

An account open for one day can count

For example, you opened a foreign savings account in February, held $14,000 in it in June, and closed it in August. If you are a U.S. person with a financial interest in it and no exception applies, it goes on that year's FBAR; the December 31 balance of zero doesn't remove it.⁠Source 1⁠Source 2

If all your foreign accounts together stayed at $10,000 or less, opening and closing an account during the year doesn't trigger a filing. Check the aggregate threshold and applicable exceptions.⁠Source 1⁠Source 2

What do I report for a closed account?

Report the greatest value of the account while it was open during the calendar year, not zero because it is now closed. Record the owner, account number, account type, bank name and address, and the maximum. Convert the maximum at the Treasury rate for December 31 of the reporting year, even if the account closed earlier. If the value works out negative, enter 0. The maximum account value guide has the details.⁠Source 2⁠Source 4

If you moved the money from the closing account to another foreign account, count it once when you work out whether you crossed the $10,000 threshold; see the transfer rule in the $10,000 threshold guide. Both accounts are still reported, each at its own maximum value. Keep the transfer dates with your records.⁠Source 2

Two practical closure examples

Closed midyear: a foreign brokerage account was worth $24,500 in May, liquidated in October and paid out. Its maximum value for the year is $24,500, even though the closing statement shows zero.⁠Source 2⁠Source 4

Opened and closed the same year: a foreign bank account existed from March through June and peaked at $8,000. Whether you must file depends on your other foreign accounts. If they take the total above $10,000, this account goes on the FBAR at $8,000.⁠Source 1⁠Source 2

Collect evidence before access disappears

Download account statements, closing confirmations, dates, institution address, account number and any evidence of the largest value. Closed-account documents can be harder to retrieve after online banking is disabled. Keep the account in that year's record set under the FBAR recordkeeping guide.⁠Source 1⁠Source 2⁠Source 3

Must I report a foreign bank account that was open during the year but is closed now?

Yes, if you must file for that year. An account held during the calendar year is not excluded because it later closed.⁠Source 1⁠Source 2

Do I report an account that opened and closed within the same year?

Yes, it is assessed like any account held during the year. Its highest value while open and the aggregate filing test are what matter.⁠Source 1⁠Source 2

Can I report zero because the account had a zero balance at year end?

No. Report the account's maximum value during the year, not its year-end balance.⁠Source 2⁠Source 4

Does an account with only $500 need to be reported?

Yes, if you must file because of your other accounts. There is no per-account $10,000 exemption.⁠Source 1⁠Source 2

Is an FBAR required just because I opened a foreign account?

No. The U.S.-person status, covered account, financial interest/authority and combined account-value threshold must be evaluated.⁠Source 1⁠Source 2

If the money moved to another foreign bank, does that cancel the closed account?

No. Report both accounts, each at its own maximum value. When working out the $10,000 threshold, count the transferred money once.⁠Source 2

How do I find the maximum of an account the bank has closed?

Request archived statements and closing or transaction records. If the bank didn't issue periodic statements, use the largest amount in the account at any time during the year.⁠Source 2⁠Source 3

What if the account was jointly owned?

Each joint owner who files reports the full account value, not a share; see the joint-account guide.⁠Source 1⁠Source 2

How long must I keep records for a closed account?

Five years from the FBAR due date for that reporting year. Closing the account doesn't shorten this; the recordkeeping guide explains when the period starts.⁠Source 1⁠Source 2

Common questions

Next pages

Sources

Official sources used for this page.

  1. Source 1: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)

    Calendar-year financial-interest and aggregate-value tests, and the record retention period.

    irs.govChecked Back to text

  2. Source 2: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)

    Reporting-year account valuation, transfers counted once and statements not issued.

    irs.govChecked Source updated Back to text

  3. Source 3: IRS, Details on reporting foreign bank and financial accounts (opens in a new tab)

    Account maximums and retaining supporting records.

    irs.govChecked Back to text

  4. Source 4: FinCEN, Reporting Maximum Account Value (opens in a new tab)

    Maximum value, conversion at the Treasury rate for the last day of the calendar year, and negative values entered as zero.

    fincen.govChecked Back to text

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